Department of Homeland Security Regulatory Impacts on Monetizing Risk for Disinfection Alternatives Analysis May 10, 2013 Donnie Stallman
Outline • Trends and status of chlorine gas disinfection • Drivers • Safety • Regulatory • Impacts on chlorine disinfection lifecycle analyses • Example: Joint Water Commission’s Fernhill Water Treatment Plant (JWC WTP) Brown and Caldwell 2
Chlorine Gas Disinfection • New/pending regulations for storage and handling of Cl 2 gas • Fewer manufacturers/suppliers of Cl 2 gas • Response to more stringent regulations • Municipalities reconsidering water/wastewater disinfection options • Cl 2 gas typically the apparent lowest cost chlorine disinfection alternative Brown and Caldwell 3
Drivers and Regulatory Responses • Safety Concerns • Regulatory • Domestic accidents • Prompted by safety concerns • Potential security risks • Numerous governing agencies/bodies for Cl 2 gas • More regulation on the way? Brown and Caldwell 4
Safety Drivers • Events in U.S. (Transportation and Handling) • Graniteville, SC – 2005 • Port of Tacoma, WA – 2007 • Las Vegas, NV – 2007 Brown and Caldwell 5
Safety Drivers • Events in Iraq (Used as a weapon) • 2007 – over ten events where chlorine was used as a weapon. • Targeting trucks that were transporting chlorine gas. Brown and Caldwell 6
Regulations What governing bodies have regulations/guidelines for transport, storage and use of chlorine? • UFC (Uniform Fire Code) and • The 10 States Standards IFC (International Fire Code) • AWWA (American Water Works • USEPA (U.S. Environmental Association) Protection Agency) • OSHA (Occupational Safety • USDOT (U.S. Department of and Health Administration) Transportation) • NIOSH (National Institute of • PHMSA (Pipeline and Occupational Safety and Hazardous Materials Safety Health) Administration) • DHS (Department of • The Chlorine Institute Homeland Security) • NFPA (National Fire Protection Association) Brown and Caldwell 7
Department of Homeland Security (DHS) • Chlorine tank explosion is one of DHS national planning scenarios. • SAFETY (Support Anti-terrorism by Fostering Effective Technologies) Act. • Created in 2002 • Incentivizes development/deployment of anti-terrorism technologies • Establishes Qualified Anti-Terrorism Technology (QATT) Brown and Caldwell 8
Qualified Anti-Terrorism Technology (QATT) • How to promote development/deployment of anti- terrorism technologies? • “Ensure the threat of liability does not deter potential manufacturers…” • Limited liability for claims related to an act of terrorism • Immune to punitive damages • QATT Certifications: • 2003 – 2005: six designated QATTs • Since 2005: approx. 70 more • Klorigen: Certified QATT in 2010. Brown and Caldwell 9
Other Proposed Regulations • Several bills have been proposed addressing storage/use of chlorine that have not been passed into law yet (?) • Chemical Facility Anti-Terrorism Act, 2009 • Drinking Water System Security Act, 2009 • Secure Water Facilities Act, 2010 Brown and Caldwell 10
Chlorine Gas Availability • Industrial production in U.S. exceeds 15 million tons/yr • Fewer than 20 states produce • Large quantities must be transported Brown and Caldwell 11
Chlorine Gas Availability • Pacific Northwest • Jones Chemical, Inc – only Cl 2 gas vendor in WA • Sierra Chemical Co. Northern CA and Southern OR. • Thatcher: MT, ID, and UT • Hypochlorite also relies on transport of Cl 2 gas • Not immune to security regulations on Cl 2 gas transport • More numerous suppliers • Subject to less regulatory pressure Brown and Caldwell 12
Chlorine Gas Transport 90-ton train tanker 1-ton cylinder 150-lb NaOCl cylinders Brown and Caldwell 13
Case Study: Joint Water Commission 14
Joint Water Commission (JWC) • Fernhill Water Treatment Plant (JWC WTP) • Distributes finished water to Hillsboro, Forest Grove, Tualatin Valley Water District, and Beaverton • 75 MGD peak day design capacity • Chlorine Gas Disinfection: Existing JWC WTP Chlorinator Sizing and Description Unit no. Capacity, pounds per day (ppd) Primary application Control 1 1,000 Post sedimentation basin flume Flow paced 2 1,000 Clearwell Flow paced 3 150 FWPB 2 Flow paced 4 150 FWPB 1 Flow paced 5 750 Rapid mix Flow paced Total capacity 3,050 Firm capacity 2,050 15
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Alternatives Analysis Alterna nati tive Type/S /Strength trength Chlorine Gas Ton containers Bulk Liquid Sodium Hypochlorite 12% delivered Onsite Generation (low strength) 0.8% Onsite Generation (high strength) 12.5% Brown and Caldwell 17
Level of Service Considerations • operator safety • public safety • ability to meet 2028 design conditions • 70 mgd average, 135 mgd peak • ease of expansion to meet 2047 design conditions • 91 mgd average, 175 mgd peak • maintenance and energy costs • risk of supply chain interruptions Brown and Caldwell 18
Lifecycle Cost Analysis • 20 year analysis • Components: • Capital, O&M, R&R, risk • Assumptions: • Greenfield construction • Intermediate ozonation per master plan • Existing Cl 2 gas scrubber could be used • Caustic savings included for hypochlorite alternatives Brown and Caldwell 19
Lifecycle Cost Analysis Major Cost Estimation Components Bulk Liquid Sodium Chlorine Gas Onsite Hypo Generation (0.8%) Onsite Hypo Generation (12.5%) Hypochlorite Capital • Chlorinators • Storage tanks • Onsite generation equipment • Onsite generation equipment • New building • Metering and transfer pumps • New building • New building • New building • Storage tanks • Storage tanks • Metering and transfer pumps • Metering and transfer pumps O&M • Delivery of ton • Delivery of liquid hypo • Salt • Salt containers • Caustic • Power for electrolyzers • Power for electrolyzers • Caustic • General maintenance • Caustic • Caustic • General maintenance • General maintenance • General maintenance Assumptions • $465/Cl 2 gas ton • $0.79/gallon delivered liquid • $0.033/lb of salt • $0.033/lb of salt container sodium hypochlorite • $414/ton of caustic • $414/ton of caustic • $414/ton of caustic • $414/ton of caustic • 28 percent reduction in caustic • 28 percent reduction in • Existing Cl 2 scrubber • 28 percent reduction in caustic per RTW modeling caustic per RTW modeling can be used per RTW modeling • $0.10/kilowatt hour (kWh) • $0.10/kWh Brown and Caldwell 20
Monetizing Risk • Supply chain interruption • No access to Cl 2 gas deliveries for 1 week each year • Liquid hypochlorite delivered at an inflated rate as emergency measure • Truck rental/demurrage and metering pump rental costs Cost st Item Annual al Risk Cost ($/yr yr) Inflated Bulk Liquid Hypochlorite $56,000 Truck Rental/Demurrage $21,000 Metering Pumps $5,000 Tot otal al $82,000 00 Brown and Caldwell 21
Net Present Value Results Chlorine Disinfection Alternatives Net Present Value Capital cost, O&M cost, R&R cost, Risk cost, Alternative Description NPV present value present value present value present value 1 Chlorine Gas $2.77 million $11.6 million $265,000 $1.56 million $16.2 million Bulk Liquid Sodium 2 $2.31 million $12.1 million $336,000 - $14.8 million Hypochlorite (12%) 3 Onsite Hypo Generation (0.8%) $7.32 million $9.76 million $1.48 million - $18.6 million 4 Onsite Hypo Generation (12.5%) $9.86 million $11.8 million $1.84 million - $23.5 million Chlorine Disinfection Alternatives Net Present Value Capital cost, O&M cost, R&R cost, Risk cost, Alternative Description NPV present value present value present value present value 1 Chlorine Gas $2.77 million $11.6 million $265,000 - $14.6 million Bulk Liquid Sodium 2 $2.31 million $12.1 million $336,000 - $14.8 million Hypochlorite (12%) 3 Onsite Hypo Generation (0.8%) $7.32 million $9.76 million $1.48 million - $18.6 million 4 Onsite Hypo Generation (12.5%) $9.86 million $11.8 million $1.84 million - $23.5 million Brown and Caldwell 22
Conclusions • Safety and regulatory drivers are motivating municipalities to reconsider disinfection options. • Establishment of QATTs by DHS telling example of how regulating bodies are looking at chlorine gas. • There are significant risk costs to be considered when evaluating chlorine gas as a disinfection alternative. • Delivered liquid sodium hypochlorite was determined to be the lowest long-term cost solution for the JWC WTP. Brown and Caldwell 23
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